1. Sump Water Management and Disposal ASTSWMO UST Workshop
Sump Water Management and Disposal ASTSWMO UST Workshop. Louisville, KY May 24, 2017
Tom DeNormandie
UST Program Manager
Massachusetts Department of Environmental Protection
(617)

2. MassDEP UST Program
July 1, 2009 UST Program transferred from Massachusetts Department of Fire Services to Department of Environmental Protection
January 2, 2015 MassDEP adopted 310 CMR Underground Storage Tank Systems

3. 310 CMR 80.00 Underground Storage Tank Systems
All Turbine, Intermediate and Dispenser Sumps are required to be tested once on or before January 2, 2017 using a pressure, vacuum or hydrostatic test.
If a hydrostatic test is used, only need to fill the sump to the level that would activate the sump sensor.
If a sump does not have a sump sensor, and a hydrostatic test is used, sump must be filled to the top of the sump
All Product Fill Spill Buckets required to be tested on or before January 2, 2017, and every 5 years thereafter, using a hydrostatic or vacuum tests.
If a hydrostatic test is used, spill buckets must be tested to the top of the bucket.

4. RE-USE OF TEST WATER
No limitation on the number of times test water from hydrostatic testing of sumps and spill buckets can be used.
Determination of whether test water is hazardous waste or not is not required until test water is about to be discarded.

5. Management of Gasoline/Water Mixtures
Massachusetts mirrors the EPA Commercial Chemical Product exemptions for the management of hazardous gasoline/water mixtures, but with more conditions regarding container management, shipping and paperwork.
Massachusetts has a state-specific exemption for these hazardous gasoline/water mixtures.

6. Gasoline/Water Mixtures Exemptions
Hazardous Mixture: If the gasoline/water mixture is found to be hazardous, it can be sent for reclamation under a MassDEP exemption. There are 3 options for managing hazardous gasoline/water mixtures.

7. Gasoline/Water Mixtures Exemption (Hazardous)
Option 1: Manage the hazardous mixture under the exemption for mixtures that are sent for reclamation.
Under this exemption, the generator may ship the wastewater off-site by:
Common carrier under a bill-of-lading (BOL)
Licensed hazardous waste transporter using a manifest or BOL

8. Gasoline/Water Mixtures Exemption (Hazardous)
Option #1 (continued):
The generator must ensure that:
Wastewater is accumulated in containers that are:
Sealed
Structurally sound
Labeled as “Gasoline/Water Mixture for Reclamation – Ignitable – Toxic – Benzene”

9. Gasoline/Water Mixtures Exemption (Hazardous)
Option #1 (continued):
The generator must ensure that:
Records from the recycling company demonstrating receipt of shipment and that the shipment was recycled in compliance with state and federal laws
The recycling facility signs the BOL or manifest acknowledging the receipt of the material
The recycling facility returns a signed copy of the BOL or manifest to the generator of the hazardous gasoline/ water mixture

10. Gasoline/Water Mixtures Exemption (Hazardous)
Option 2:
Ship the wastewater off-site as a hazardous waste using a licensed hazardous waste transporter; or

11. Gasoline/Water Mixtures Exemption (Hazardous)
Option 3:
If the generator is a VSQG in Massachusetts, they can self-transport a maximum of one 55-gallon drum at one time to another hazardous waste generator or to a licensed hazardous waste facility.

12. Gasoline/Water Mixtures (Non-Hazardous)
For gasoline/water mixtures that are non-hazardous, MassDEP also has 3 options:
Option 1:
Ship the mixture off-site to an industrial wastewater facility on a Bill-of-Lading (BOL) for treatment and disposal;

13. Gasoline/Water Mixtures (Non-Hazardous)
Option 2:
Discharge the mixture to a sewer connection in compliance with the owner’s sewer permit or with permission of the local sewer authority; or

14. Gasoline/Water Mixtures (Non-Hazardous)
Option 3:
Add the non-hazardous mixture to the hazardous gasoline/water mixtures at the facility. Manage the hazardous wastewater in compliance with the hazardous waste management options on the previous slides.

15. Gasoline/Water Mixtures (Non-Hazardous)
Non-hazardous gasoline/water mixtures:
CANNOT be discharged onto the ground, into surface waters or storm drains, or into a septic system!
May ONLY be discharged to a sewer with the permission of the local sewer authority.
Don’t Do This!

16. Diesel or Kerosene/Water Mixtures (Waste Oil)
In Massachusetts, diesel/water mixtures and kerosene/water mixtures are regulated as “waste oil”, if a discernable layer of the substance can be seen on the water’s surface (i.e., more than a sheen).
If these mixtures are NOT contaminated with hazardous or other wastes, there are 5 options for handling.

17. Diesel or Kerosene/Water Mixtures (Waste Oil)
Option 1:
Recycled directly by burning for energy recovery in equipment designed to burn diesel or kerosene
Please note that a water separator may be necessary to process the fuel prior to burning
Option 2:
Shipped off-site as used fuel to a facility that separates the water layer and markets the oil layer to burners or other marketers of used fuel.
Option 3:
Shipped off-site as used oil fuel directly to a facility the burns the fuel after separation of the water layer (a recycling permit may be necessary); or

18. Diesel or Kerosene/Water Mixtures (Waste Oil)
Option 4:
The wastewater is mixed with other waste oils generated on-site and recycled per Options 2 and 3
Option 5:
Ship the wastewater off-site as waste oil on a hazardous waste manifest

19. Diesel or Kerosene/Water Mixtures (Waste Oil)
One more caveat:
Diesel/water and kerosene/water mixtures with only a SHEEN on the water surface are NOT a “waste oil” in Massachusetts, but can be managed as a non-hazardous oily industrial wastewater using the options listed previously under “non-hazardous gasoline/water mixtures”.

20. Massachusetts Resources
The Very Small Quantity Generator of Hazardous Waste (VSQG)
A Summary of Requirements for Small Quantity Generators of Hazardous Waste
Know Your Generator Status & Storage Limits
Safe Handling of Waste Oil for Burning in Space Heaters
Waste Oil, Used Oil Filters, and Waste Oil Space Heaters